Such companies as Apple, Google, and Microsoft have used offshore subsidiaries and company affiliates to achieve sizable geographic tax savings over the years. But it's the tax implications of the allocation of those offshore profits among subsidiaries "” their transfer pricing "” that ranked as a top tax concern for 2013, according to a November 2012 survey by CEB (formerly the Corporate Executive Board), a member-based research advisory, of 64 global tax directors from companies making more than $1bn in revenue.

Transfer-pricing taxation came in second behind political risk in terms of the likelihood that the issue will actually heat up this year. "Tax departments are being asked to cope with transfer-pricing documentation requirements that are growing by the day," according to the survey report, which notes that corporate tax directors "are also grappling with inconsistent enforcement across different revenue authorizes. Organizations are bracing themselves for a larger number of transfer pricing investigations and penalties."